Introduction

In United States v. Kartayah Nariah Feliciano, No. 23-13414 (11th Cir. Oct. 20, 2025) (per curiam) (unpublished), the Eleventh Circuit affirmed a below-Guidelines sentence of 60 months for a defendant who participated in a cruise-ship drug-smuggling operation. The appeal raised two recurring sentencing issues in drug cases:

• Whether the district court erred in attributing to the defendant not only the cocaine found in her own possessions, but also the quantities found on her co-travelers, under the “relevant conduct” rule for jointly undertaken criminal activity (U.S.S.G. § 1B1.3).
• Whether the district court erred in denying a mitigating role reduction for a purported “unknowing” or peripheral courier (U.S.S.G. § 3B1.2).

The panel held there was no clear error in either finding. The case provides a useful, fact-driven illustration of how the scope, in-furtherance, and foreseeability elements of § 1B1.3 apply to couriers who travel together and share logistics; and it reinforces the Eleventh Circuit’s two-part framework under Rodriguez De Varon for denying minor-role reductions where the defendant’s participation is essential, informed, and remunerated.

Although the opinion is “Not for Publication” and therefore non-precedential, it consolidates core Eleventh Circuit approaches to jointly undertaken criminal activity and role reductions in a familiar factual setting.

Case Overview

Defendant-Appellant: Kartayah Nariah Feliciano

Plaintiff-Appellee: United States of America

Court: United States Court of Appeals for the Eleventh Circuit (Non-Argument Calendar); Panel: Chief Judge William Pryor, and Judges Abudu and Anderson; Disposition: Affirmed.

Background Facts

• In October 2022, co-defendant Melinna Destra recruited Feliciano for a “free” Caribbean cruise with a promise of $1,600; Feliciano sensed something was “not right,” but agreed.
• On the way to Miami, Destra provided Feliciano a backpack and instructed her to use it. At a Jamaican port, Destra, Feliciano, and Jacqueline Mason disembarked with backpacks, left them with individuals, and later had the backpacks returned. Before reboarding, Destra also gave Feliciano and Mason a handbag.
• Back in her cabin, Feliciano noticed unusual stitching and a “crinkling” sound in her backpack, suspected drugs, and asked Mason—who replied Destra had “done this before.”
• At disembarkation, Customs and Border Protection discovered 16.042 kilograms of cocaine concealed among the three women’s belongings, including 4.983 kilograms in Feliciano’s handbag and backpack lining.

Charges and Sentencing

• Feliciano pleaded guilty to importing cocaine (21 U.S.C. § 952(a)) and possession with intent to distribute (21 U.S.C. § 841(a)(1)).
• Guidelines calculations (Nov. 2021 Manual): Base offense level 32 (U.S.S.G. § 2D1.1(a)(5), (c)(4)) based on the full 16.042 kg; minus 2 for safety-valve eligibility (§ 2D1.1(b)(18)); minus 3 for acceptance of responsibility (§ 3E1.1(a), (b)). Total offense level: 27; Criminal History Category I; advisory range: 70–87 months.
• Objections: Feliciano argued (i) she should be accountable only for the drugs in her own bags; and (ii) she was entitled to a mitigating role reduction.
• District court: Overruled objections, finding an “obviously” joint venture with unified logistics; held Feliciano’s role akin to Mason’s (who received no role reduction); imposed a below-Guidelines 60-month sentence.

Summary of the Opinion

The Eleventh Circuit affirmed in full. Applying clear-error review, it held:

• Drug quantity attribution: The district court did not clearly err in attributing the full 16.042 kilograms to Feliciano because the evidence showed a jointly undertaken criminal activity whose scope encompassed the importation and distribution of cocaine by all three women. The co-participants’ quantities were within the scope and in furtherance of that joint venture and reasonably foreseeable to Feliciano (U.S.S.G. § 1B1.3 & cmt. n.3(D)).
• Mitigating role: The court did not clearly err in denying a § 3B1.2 reduction. Feliciano was an essential courier transporting roughly one-third of the load; she understood the operation’s scope (suspected drugs, recognized altered bag, was told this had been done before) and stood to benefit (free trip and promised payment). Under De Varon’s analytical framework, her role was not “minor” relative to the relevant conduct or to her co-participants.

Analysis

Precedents Cited

• United States v. Azmat, 805 F.3d 1018, 1046 (11th Cir. 2020): The panel cites Azmat for the clear-error standard in attributing drug quantities. Azmat underscores that factual findings about the scope of jointly undertaken activity and foreseeability are entitled to deference unless the reviewing court is left with a firm conviction of mistake. The Feliciano panel uses Azmat to frame its deferential review of the district court’s “joint venture” and foreseeability findings.
• United States v. Valois, 915 F.3d 717, 730 n.8, 731 (11th Cir. 2019): Cited for the clear-error standard in denying role reductions, Valois reaffirms that appellate courts do not reweigh sentencing evidence de novo. The touchstone is whether the district court’s view is plausible on the record as a whole.
• United States v. Rodriguez De Varon, 175 F.3d 930, 940–45 (11th Cir. 1999) (en banc): The Eleventh Circuit’s seminal framework for § 3B1.2. De Varon directs district courts to assess (1) the defendant’s role in the relevant conduct for which she is held accountable and (2) her role compared to other participants in that conduct. De Varon also cautions that couriers can be essential participants and are not automatically entitled to a role reduction. The Feliciano panel follows this approach: it finds the defendant’s participation essential to the importation and not meaningfully less culpable than her co-courier Mason.
• United States v. Wenxia Man, 891 F.3d 1253, 1274 (11th Cir. 2018): Cited to clarify that the defendant bears the burden to prove entitlement to a mitigating role reduction by a preponderance of the evidence. The panel held Feliciano did not carry that burden on the facts.

Legal Reasoning

1) Relevant Conduct and Jointly Undertaken Criminal Activity (U.S.S.G. § 1B1.3)

The Guidelines require sentencing courts to account for “all quantities of contraband with which [the defendant] was directly involved,” and for quantities handled by other participants in cases of a “jointly undertaken criminal activity,” provided the other participants’ conduct was (i) within the scope of, (ii) in furtherance of, and (iii) reasonably foreseeable in connection with that jointly undertaken activity. See § 1B1.3 cmt. n.3(D).

The district court found, and the panel agreed, that these elements were satisfied:

• Scope: The three women boarded and disembarked together, surrendered their backpacks for concealment work and retrieved them, and were each handed additional handbags before reboarding. The court reasonably inferred a single, coordinated plan to import cocaine using identical methods and synchronized logistics.
• In furtherance: Each woman’s role served the shared objective: importation and distribution of cocaine. The multiple carriers diluted detection risk and maximized drug import volume, both in service of the jointly undertaken criminal activity.
• Foreseeability: Feliciano noticed altered stitching, heard a crinkling sound suggesting hidden contraband, suspected drugs, and was told by Mason that Destra had “done this before.” On these facts, it was reasonably foreseeable that the other identically-situated couriers were transporting cocaine in the same manner and for the same purpose.

Because these factual findings are plausible and supported by the record, the Eleventh Circuit—under clear-error review—refused to disturb the district court’s attribution of the entire 16.042 kilograms.

2) Mitigating Role (U.S.S.G. § 3B1.2) and the De Varon Framework

The defendant sought a minor-role reduction, contending she was at most an “unknowing drug mule.” The panel disagreed for two independent reasons consistent with De Varon:

• Role in her relevant conduct: Feliciano accepted and carried bags, thereby serving as an “important or essential” courier responsible for importing approximately one-third of the total load. She recognized indicators of concealment, suspected the presence of drugs, and nonetheless proceeded. The nature and extent of her participation were meaningful, not peripheral.
• Relative culpability among participants: The district court found Feliciano’s role “akin to Mason’s,” and Mason did not receive a role reduction. Without evidence that Feliciano was substantially less culpable than her co-courier, the claim for a § 3B1.2 reduction failed.

The panel additionally noted factors recognized in the Guideline commentary that cut against mitigation here: she understood the scheme’s scope and structure, had no decision-making authority but performed a core function, and stood to benefit financially (and via a free trip).

Impact and Implications

For Sentencing Law and Practice

• Attribution in courier teams: When defendants travel together, surrender and receive luggage together, and share operational logistics, courts in the Eleventh Circuit are likely to find a “jointly undertaken” activity encompassing the entire load—even if a defendant physically carries only part of it.
• Foreseeability markers: Awareness of altered luggage, sensory cues (e.g., crinkling lining), and statements acknowledging prior smuggling (“done this before”) are potent evidence of foreseeability supporting full-quantity attribution.
• Role reductions not presumed for couriers: De Varon continues to exert gravitational force. Couriers are not “minor” simply by virtue of being couriers. A reduction generally requires proof of substantially lesser culpability than average participants in the same relevant conduct—often by showing extremely limited knowledge, lack of benefit, no discretion, and replaceability beyond the norm.
• Party stipulations do not control the court’s duty: Even if parties discuss a narrower quantity, the court must independently calculate the Guidelines based on relevant conduct. The sentencing judge is not bound to adopt the parties’ characterization if the facts show a broader jointly undertaken activity.
• Safety valve is independent of role: Eligibility for the statutory safety valve (recognized here via the two-level § 2D1.1(b)(18) reduction) does not entail a mitigating role reduction. They serve different purposes and are decided under distinct criteria.
• Downward variance still possible without role reduction: The 60-month sentence here was below the 70–87 month range calculated without a role reduction. Defense counsel should remember that even unsuccessful role objections can be followed by persuasive § 3553(a) variance arguments tailored to personal mitigating facts.

Practical Takeaways for Counsel

• Narrowing “scope” evidence: To avoid full-load attribution, develop evidence showing that the defendant did not agree to jointly undertake a multi-carrier plan: no shared planning, no awareness of others’ participation, and separate, compartmentalized logistics.
• Challenging foreseeability: Aim to rebut indicators like altered bags or admissions of suspicion. A true “blind mule” defense requires credible proof of ignorance incompatible with the sensory and circumstantial cues present here.
• Minor-role proof under De Varon: Emphasize concrete differences from co-participants (no payment or markedly lesser benefit; unique vulnerability; coercion; no knowledge of the scheme’s breadth; easily replaceable role). Show why the defendant is “substantially less culpable” than the average participant in the relevant conduct.
• Leverage comparator parity: If a co-defendant received a minor-role reduction, build a parity record; conversely, if co-defendants did not, be prepared to differentiate your client’s indicia of lesser culpability.

Complex Concepts Simplified

• Clear-error review: An appellate court won’t reverse a district court’s factual findings unless it is left with a “definite and firm conviction” that a mistake occurred. If the district court’s view is one of several reasonable interpretations of the record, it stands.
• Relevant conduct (U.S.S.G. § 1B1.3): For sentencing, a defendant’s Guidelines exposure can include conduct beyond her own acts. In a joint criminal undertaking, she can be accountable for others’ acts that fall within the scope of what she agreed to, further the joint plan, and were reasonably foreseeable to her.
• Jointly undertaken criminal activity: This is narrower than conspiracy liability. It covers the particular criminal plan the defendant agreed to and participated in. The court examines what the defendant “jointly undertook,” not everything all conspirators ever did.
• Mitigating role (U.S.S.G. § 3B1.2): “Minimal” (−4) and “minor” (−2) roles reduce offense levels. The defendant must prove she is substantially less culpable than most participants in the relevant conduct. Being a courier is not automatically “minor”; the court considers knowledge, decision-making, benefit, and the nature and extent of participation.
• Safety valve (§ 2D1.1(b)(18) / 18 U.S.C. § 3553(f)): If eligible (e.g., limited criminal history, non-violence, truthfully providing information), a drug defendant can avoid mandatory minimums and receive a two-level reduction. This is separate from role adjustments.
• Acceptance of responsibility (§ 3E1.1): Defendants who plead guilty and demonstrate acceptance typically receive a 2- or 3-level reduction, reflecting acknowledgment of wrongdoing and conservation of resources.

Conclusion

United States v. Feliciano reinforces two enduring Guide­lines propositions in the Eleventh Circuit: (1) courier teams who travel together and share logistics can be treated as engaging in a jointly undertaken criminal activity, making each courier accountable for the full drug quantity if scope, furtherance, and foreseeability are satisfied; and (2) a courier is not entitled to a mitigating role reduction merely by virtue of courier status where the record shows essential participation, awareness of the scheme, and anticipated benefit.

While unpublished and thus non-precedential, the opinion is a practical primer on how routine—but powerful—sentencing doctrines operate in drug-importation cases. It signals to district courts and counsel alike that evidence of shared travel, coordinated bag exchanges, and defendant awareness will sustain full-quantity attribution and defeat claims of minor role under the exacting, deferential clear-error standard.

Case Metadata

• Case: United States v. Kartayah Nariah Feliciano
• Court: U.S. Court of Appeals for the Eleventh Circuit
• Date: October 20, 2025
• Disposition: Sentence affirmed
• Opinion: Per curiam; Not for publication; Non-Argument Calendar
• Key Authorities: U.S.S.G. §§ 1B1.3, 2D1.1, 3B1.2, 3E1.1; United States v. Azmat; United States v. Valois; United States v. Rodriguez De Varon; United States v. Wenxia Man